MAH Risk Register

Objective of MAH (Major Accident Hazard) risk register development exercise is to develop detailed / comprehensive MAH risk register which are dynamic in nature and can be regularly maintained for tracking live compliance status.

MAH risk register development will be done comprehensively, which captures unit level / equipment specific MAH scenarios and incorporate the outcome from Technical Site Survey report, Bow Tie development workshop, MCEs and MCTs developments workshop, Performance Standard development exercise for MCEs and MCTs, MOPO development exercise, Vehicle impact assessment and QRA.

Steps involved in the development of MAH risk register

• Data gathering
• MAH identification
• Formulation of MAH risk register
• Development of MAH risk register
• Action/Recommendation
• Report

The term “MAH” refers to an uncontrolled event that may occur during the operation of a Facility, installation, or project. Such an event has the potential to cause a fire, explosion, or release of Hydrocarbons, Chemicals, or other substances that could result in multiple fatalities or serious personal injury to multiple individuals. Additionally, an MAH event may cause significant damage to Facility, installation, or equipment, including a loss in the stability of the installation. Furthermore, an MAH event may result in major environmental consequences.

MAH identification will be done by referring HAZID, HAZOP, LOPA / SIL, QRA and SIMOP, where MAH identification was already carried out and include those identified MAHs into the facility MAH risk register. The risk ranking revalidation exercise is intended to identify the wrongly attributed MAHs or missed MAHs from these reports and include the right MAH scenarios in MAH risk register.

HAZID is used for systematic identification of the cause and consequence of safety and environmental hazards and their safeguards. This method is used to identify credible MAHs by risk ranking.

Hazard and Operability technique is a process of hazard and operability issue identification that can include or be followed by a risk ranking process to identify credible MAHs. HAZOPs uses a structured approach, to obtain comprehensive coverage of all relevant operability hazards. HAZOP study identifies the process system design issues, some of which might lead to MAH.

SIMOPS is a technique for identification of potential hazards and threats resulting from simultaneous or concurrent activities such as construction and operation, drilling and work over or drilling and operations. The scale and severity of restrictions imposed through SIMOPS document indicate the potential for major accidents in case the activities are allowed for simultaneous execution. The associate risk of such scenarios will be captured in MAH risk register with appropriate barriers to mitigate the consequence.

Quantitative risk assessment (QRA) is a technique to evaluate the risk profile of facility, under its normal operations, due to both process activities and non-process activities. The risk identified from both activities will be captured in MAH Risk Register.

MAH risk register is created to capture all MAH events listed from safety studies. The MAH risk register template consists of following fields,

• Bow Tie Reference
• Hazard
• Causes (Threat)
• MAH Scenario Description
• Consequence / Impact Description
• Legal or Other Compliance Requirement Reference
• Existing Preventive safeguards
• Existing Mitigation safeguards
• Inherent Risk for all four categories (People, Asset, Environment and Reputation)
• Recommended additional Preventive safeguards
• Recommended additional Mitigation safeguards
• Residual Risk for all four categories (People, Asset, Environment and Reputation)
• Implementation date for recommendations (additional safeguards / control measures)
• Accountable person
• Incorporated Controls / Resolution
• Assurance activities
• References and Links of relevant safety studies
• HSE Opportunities for improvement
• Action Completion Status
• Remarks / Comments

The MAH identified from safety studies (HAZOP, HAZID, QRA, etc.) and Risk register will be updated throughout the project life with input from Technical site survey report which shall aid in the population of  MAH risk register with due consideration of existing safeguards, its condition, relevance and effectiveness. Outcomes from Bow Tie development workshop, MCEs and MCTs Identification workshop, Performance Standard development exercise for MCEs and MCTs,

MOPO development exercise, Vehicle impact assessment and QRA are also updated in MAH risk register throughout the project life cycle. The ALARP demonstration shall be done for all recommendations identified in MAH Risk Register. ALARP demonstration requires the following steps:

• MAH hazard identification and risk reduction measures (RRM) identified (MAH HAZID/ENVID, HAZOP).
• Consequence and frequency assessment (LOPA/SIL, Bow Tie analysis, FSA).
• Aggregation and assessment of risk demonstrating that all risk are within acceptable or acceptable if ALARP region (QRA).
• Identification and assessment of further RRMs (ALARP Demonstrations).
• Demonstration that further RRMs have been adopted or provide disproportionately low risk reduction as compared to the cost of implementation

The Cost Benefit Analysis is performed for all recommendations taken from MAH Risk Register, except for the recommendations that meet the below mentioned criteria.

• Basic engineering study is required to estimate the bill of material which in turn is required to carry out a cost benefit analysis
• The implementation of high/low deviation alarms in the current distributed control system (DCS), as well as alterations to control logic without the incorporation of new instruments, are proposed
• The modification of emergency shutdown (ESD) interlocks through logic adjustments without the addition of new instruments is suggested
• Designating existing alarm as critical alarm
• The proposed actions include updating the Standard Operating Procedure (SOP), incorporating dead zones for corrosion monitoring, and enhancing the frequency of preventive maintenance
• P&ID and other document corrections
• Studies including alarm audits
• Low-cost recommendations, such as the provision of NRVs and blinds, are suggested.
• The MAH risk register prepared comprehensive for each production facilities / stations / operating units/ equipment specific MAH scenarios so that the identified and listed safeguards are not generic but very specific to the MAH scenario under consideration. The identified inadequacies and recommendation will be captured in MAH risk register. Criticality ranking of all recommendations from a risk based perspective will be done. The recommendations will be mapped against the relevant CCPS PSM element(s).

The findings of MAH risk register for each Production Facilities / stations and operating units will be prepared as a separate detailed Draft Report for review and approval with tangible examples from best practices, case studies, etc. Final report will be submitted upon incorporation of all comments